Thank you for the opportunity to comment on the recent draft Commission report, A Comprehensive Assessment of Public Information Dissemination, Vol. 1, December 15, 2000 and the proposed legislation, The Public Information Resources Reform Act of 2001. As participants in the various stages of this and related information policy debates over the course of many years, we appreciate the depth and breadth of issues and policies that require consideration and evaluation. The Commission is to be commended for undertaking a review of such important and difficult public policy issues.

Given the enormity and importance of issues covered with a limited amount of time available for review and discussion by our communities, this letter is a first step in outlining key concerns and reactions to various recommendations included in the draft report. Once our communities have had the opportunity to discuss the recommendations, we will provide the Commission with additional detailed comments. As these issues have been under active discussion for well over 20 years, ample time for careful review and public discourse is essential.

We agree with a number of the Commission's recommendations and/or conclusions which provide the appropriate framework for consideration. These include:

The United States Government should formally recognize and affirm the concept that public information is a strategic national resource and agencies should engage in proactive initiatives in making their resources publicly available.

The NTIS mission and functions are fundamentally sound and that it should continue.

The NTIS business model should be updated and revenues should be derived from a mixture of three sources: appropriated funds, sales income, and reimbursements from other agencies for services provided.

The federal government plays a strategic role in creating, collecting, organizing, archiving, and disseminating government information; these NTIS functions are inherently governmental functions and should be supported with appropriated funds.

The federal government should continue with the development of prototype new portals, such as FirstGov.

We believe that there are a significant number of recommendations and/or conclusions that require more study, clarification, and discussion prior to NCLIS endorsement. These include but are not limited to:

Consolidating, simplifying, and streamlining the government-wide public information services organizations into a single, new Executive Branch agency, the Public Information Resources Administration, and creating comparable organizations in both the Judicial and the Legislative Branches.

What are the implications of shifting primary dissemination responsibilities to the Executive Branch from the Legislative Branch? In addition, during the last two Administrations we have witnessed efforts to streamline and downsize government. Is the consolidation of functions and the creation of new agencies viable given this trend? It would be useful to have data that would show how under this new model public access to government information would be improved. Moreover, past history has shown us that information policy debates and title 44 reform in particular, take years, indeed decades. Thus as Congress and others debate the merits of this new model of federal information dissemination, short-term action is needed to address the critical NTIS situation. We strongly urge the Commission to move forward with recommendations to ensure the future stability and growth of NTIS, separate from the Commission's broad based approach.

Conduct a congressional review of hundreds of laws that Congress has enacted for the purpose of assessing the government's cumulative public information resources program.

During an earlier title 44 review, the Congressional Research Service compiled a list of the statutes that require federal agencies to disseminate government information. Such a review as called for by the Commission would entail an enormous investment of congressional time and resources yet the benefits of such a review are not well defined nor is it clear how such a review would contribute to enhancing public access to government information.

The President should require an Information Dissemination Budget line item; for the STI component the Congress should enact legislation that automatically reserves at least three one-hundredths of one percent of all funds appropriated for research, development, and comparable government and government funded activities; and for a non-STI component.

Although an intriguing model, the .03% figure appears to be well below the current expenditures of a number STI agencies thus would reduce the federal investment in these activities. Supporting data and research are needed prior to advancing such a recommendation. In addition, the figure proposed for public information dissemination programs (GPO) and relevant public good functions of NTIS is well below the FY2001 appropriations figures for GPO and the funding needed for NTIS services.

The Library Services and Technology Act (LSTA) is an excellent financing mechanism to utilize for helping to fund the education and training of librarians and other information professionals.

LSTA funds are extremely limited and the requests for funding far exceed available funds. Indeed, National Leadership Grants are limited to 3.75% of the IMLS library appropriation and these are devoted to a number of different arenas such as joint library/museum collaboration and preservation or digitization of library materials.

Public and private sector partnerships should be strengthened, extended and expanded where the private sector can serve as the government's agent in a wide variety of roles.

This recommendation requires further study and discussion concerning what roles are inherently governmental or mission related vs. partnering with not-for-profit and for profit entities in public dissemination activities.

Finally, addressing preservation and access issues is a critical component to any ongoing or new federal information dissemination program and merits careful and detailed study beyond what has been accomplished to date. Indeed, increased attention is mandated as these issues drive much of the debate. We believe that the solution should be a coordinated, collaborative approach involving government entities across all three branches of government and library and archive partners. To spark additional discussions, it may be helpful for the Commission to review statutory language drafted by the library community during the 105th Congress. We note that a number of terms are used interchangeably throughout the draft report concerning preservation and access issues. As a number of terms are included in different statutes, it is important be consistent with these terms supported by the archival and library communities.

Overall, the draft report includes a number of thoughtful and important discussions but unfortunately its attempt at comprehensiveness makes it difficult to focus on key issues and recommendations. In addition, in many instances more data and analysis is required to support some of the Commission's recommendations, in particular the notion of creating new agencies. We believe when assessing the benefits and drawbacks of the various options, the benchmark should be on what is the best means to improve access to and use of government information by the public. Finally, it would be helpful to include more information regarding current technology trends. Any new organizational models should be developed with a full appreciation of the current and evolving technological capabilities of the networked environment that facilitate distributed information collection, processing, and dissemination of information.